1. GENERAL PROVISIONS
1.1. This privacy policy of the Online Store is informative, which means that it is not a source of obligations for Service Recipients or Customers of the Online Store. The privacy policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Store, including the bases, purposes, and scope of the processing of personal data and the rights of individuals whose data are processed, as well as information on the use of cookies and analytical tools in the Online Store.
1.2. The administrator of personal data collected via the Online Store is Promees Group Spółka z ograniczoną odpowiedzialnością, Piotra Skargi 129, 95-200 Pabianice, Poland; NIP: 7312080484; REGON: 524733122; KRS: 0001025017; email address: biuro@promees.pl - hereinafter referred to as the “Administrator” and being also the Service Provider of the Online Store and the Seller.
1.3. Personal data in the Online Store are processed by the Administrator in accordance with applicable law, in particular in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR). The official text of the GDPR is available at: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679.
1.4. The use of the Online Store, including making purchases, is voluntary. Similarly, the provision of personal data by the user of the Online Store is voluntary, subject to two exceptions: (1) entering into contracts with the Administrator - failure to provide personal data necessary to enter and execute a Sales Agreement or an agreement for the provision of Electronic Services with the Administrator in the cases and to the extent indicated on the website of the Online Store and in this privacy policy will result in the inability to enter into such an agreement. The provision of personal data in such a case is a contractual requirement, and if the data subject wishes to enter into a given agreement with the Administrator, they are obliged to provide the required data. Each time, the scope of data required to enter into an agreement is indicated on the website of the Online Store and in the Online Store Regulations; (2) statutory obligations of the Administrator - providing personal data is a statutory requirement resulting from generally applicable laws imposing an obligation on the Administrator to process personal data (e.g., processing data for the purpose of keeping tax books or accounting) and failure to provide them will prevent the Administrator from fulfilling these obligations.
1.5. The Administrator takes special care to protect the interests of persons whose personal data are processed, and in particular, is responsible for and ensures that the data collected by it are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that allows the identification of persons to whom they relate, no longer than it is necessary to achieve the purpose of processing; and (5) processed in a manner ensuring appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, by using appropriate technical or organizational measures.
1.6. Taking into account the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Administrator implements appropriate technical and organizational measures to ensure that processing is carried out in accordance with this regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Administrator uses technical measures to prevent the acquisition and modification by unauthorized persons of personal data sent electronically.
1.7. All words, expressions, and acronyms appearing in this privacy policy and beginning with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition contained in the Regulations of the Online Store available on the pages of the Online Store.
### 2. BASES FOR DATA PROCESSING
2.1. The Administrator is entitled to process personal data in cases where - and to the extent that - at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular, where the data subject is a child.
2.2. The processing of personal data by the Administrator each time requires at least one of the bases indicated in point 2.1 of the privacy policy. The specific bases for processing personal data of the Service Recipients and Customers of the Online Store by the Administrator are indicated in the next point of the privacy policy - in relation to the given purpose of processing personal data by the Administrator.
### 3. PURPOSE, BASIS, PERIOD, AND SCOPE OF DATA PROCESSING IN THE ONLINE STORE
3.1. Each time, the purpose, basis, period, and scope as well as the recipients of personal data processed by the Administrator result from the actions taken by the respective Service Recipient or Customer in the Online Store. For example, if a Customer decides to make purchases in the Online Store and chooses personal collection of the purchased Product instead of a courier delivery, their personal data will be processed for the purpose of executing the concluded Sales Agreement, but will not be made available to the carrier performing shipments on behalf of the Administrator.
3.2. The Administrator may process personal data in the Online Store for the following purposes, on the following bases, for the following periods, and within the following scope:
**Purpose of data processing**
**Legal basis for processing and storage period**
**Scope of processed data**
- **Performance of the Sales Agreement or a contract for the provision of Electronic Services or taking action at the request of the data subject before entering into the above-mentioned contracts:**
- Article 6(1)(b) GDPR (performance of a contract)
- Data are stored for the period necessary to perform, terminate, or otherwise expire the concluded contract.
- Maximum scope: first and last name; email address; contact phone number; delivery address (street, house number, apartment number, postal code, city, country), residential/business address (if different from the delivery address). In the case of Service Recipients or Customers who are not consumers, the Administrator may additionally process the company name and the tax identification number (NIP) of the Service Recipient or Customer. The indicated scope is maximal - for example, in the case of personal collection, it is not necessary to provide a delivery address.
- **Direct marketing:**
- Article 6(1)(f) GDPR (legitimate interest of the Administrator)
- Data are stored for the period of existence of the legitimate interest pursued by the Administrator, but not longer than the period of limitation of claims against the data subject due to the business activities conducted by the Administrator. The limitation period is specified by law, in particular, the Civil Code (the basic limitation period for claims related to business activities is three years, and for a sales contract, two years). The Administrator cannot process data for direct marketing purposes if the data subject has effectively objected to this.
- Email address
- **Marketing:**
- Article 6(1)(a) GDPR (consent)
- Data are stored until the data subject withdraws their consent to further processing of their data for this purpose.
- First name, email address
- **Newsletter:**
- If you have agreed (subscribed to the newsletter), the email address provided by you will be used for marketing purposes of our own products from promees.pl. The consent can be withdrawn at any time, for example by clicking the unsubscribe link at the bottom of the newsletter or by sending a resignation email to biuro@promees.pl.
- First name and last name, email address
- **Maintaining accounting records:**
- Article 6(1)(c) GDPR in connection with Article 74(2) of the Accounting Act of 30 January 2018 (Dz.U. 2018, item 395)
- Data are stored for the period required by law obliging the Administrator to store accounting books (until the expiry of the limitation period for tax obligations, unless tax laws provide otherwise) or accounting records (5 years, counting from the beginning of the year following the financial year to which the data relate).
- First name and last name; residential/business address (if different from the delivery address), company name, and tax identification number (NIP) of the Service Recipient or Customer
- **Establishing, investigating, or defending claims that the Administrator may raise or that may be raised against the Administrator:**
- Article 6(1)(f) GDPR
- Data are stored for the period of existence of the legitimate interest pursued by the Administrator, but not longer than the period of limitation of claims against the data subject due to the business activities conducted by the Administrator. The limitation period is specified by law, in particular, the Civil Code (the basic limitation period for claims related to business activities is three years, and for a
sales contract, two years).
- First name and last name; contact phone number; email address; delivery address (street, house number, apartment number, postal code, city, country), residential/business address (if different from the delivery address). In the case of Service Recipients or Customers who are not consumers, the Administrator may additionally process the company name and the tax identification number (NIP) of the Service Recipient or Customer.
### 4. RECIPIENTS OF DATA IN THE ONLINE STORE
4.1. For the proper functioning of the Online Store, including the execution of concluded Sales Agreements, it is necessary for the Administrator to use external service providers (such as software providers, courier companies, or payment processors). The Administrator uses only the services of such processors who provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of the data subjects.
4.2. The transfer of data by the Administrator does not occur in every case and not to all recipients or categories of recipients indicated in the privacy policy - the Administrator transfers data only when it is necessary to achieve the given purpose of the processing of personal data and only to the extent necessary to achieve it. For example, if the Customer uses personal collection, their data will not be transferred to the carrier cooperating with the Administrator.
4.3. The personal data of the Service Recipients and Customers of the Online Store may be transferred to the following recipients or categories of recipients:
- **Carriers / forwarders / courier brokers:** In the case of a Customer who uses the postal or courier delivery method in the Online Store, the Administrator provides the collected personal data of the Customer to the selected carrier, forwarder, or courier broker performing the shipment on behalf of the Administrator to the extent necessary to deliver the Product to the Customer.
- **Entities handling electronic or credit card payments:** In the case of a Customer who uses the method of electronic or credit card payments in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity handling the above payments in the Online Store on behalf of the Administrator to the extent necessary to handle the payment made by the Customer.
- **Survey system providers:** In the case of a Customer who has agreed to express an opinion on the concluded Sales Agreement, the Administrator provides the collected personal data of the Customer to the selected entity providing the survey system for the purpose of expressing an opinion by the Customer on behalf of the Administrator.
- **Providers of technical, IT, and organizational solutions:** These providers enable the Administrator to conduct business activities, including the Online Store and the electronic services provided through it (in particular, providers of computer software for running the Online Store, email and hosting providers, and software providers for managing the company and providing technical support to the Administrator). The Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only in the case and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.
- **Providers of accounting, legal, and advisory services:** These providers support the Administrator in accounting, legal, or advisory matters (in particular, an accounting office, a law firm, or a debt collection company). The Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only in the case and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.
### 5. PROFILING IN THE ONLINE STORE
5.1. The GDPR imposes an obligation on the Administrator to inform about automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR, and - at least in such cases - relevant information about the principles of their making, as well as the significance and expected consequences of such processing for the data subject. In this context, the Administrator provides information regarding possible profiling in this point of the privacy policy.
5.2. The Administrator may use profiling in the Online Store for direct marketing purposes, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a Sales Agreement or the possibility of using electronic services in the Online Store. The result of profiling in the Online Store may be, for example, granting a given person a discount, sending them a discount code, reminding them of unfinished purchases, sending a product proposal that may match the interests or preferences of a given person, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, the person makes a free decision whether they want to use the received discount or better conditions and make a purchase in the Online Store.
5.3. Profiling in the Online Store consists of an automatic analysis or forecast of a given person's behavior on the Online Store website, e.g., by adding a specific Product to the cart, browsing a specific Product page in the Online Store, or by analyzing the history of previous purchases in the Online Store. The condition for such profiling is that the Administrator has personal data of the given person to be able to send them, for example, a discount code.
5.4. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
### 6. RIGHTS OF THE DATA SUBJECT
6.1. Right of access, rectification, restriction, erasure, or data portability - the data subject has the right to request from the Administrator access to their personal data, their rectification, erasure ("right to be forgotten"), or restriction of processing, and has the right to object to the processing, as well as the right to data portability. Detailed conditions for the exercise of the aforementioned rights are indicated in Articles 15-21 of the GDPR.
6.2. Right to withdraw consent at any time - a person whose data is processed by the Administrator based on expressed consent (pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR) has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out based on consent before its withdrawal.
6.3. Right to lodge a complaint with a supervisory authority - a person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the provisions of the GDPR and Polish law, in particular, the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
6.4. Right to object - the data subject has the right to object at any time - on grounds relating to their particular situation - to the processing of their personal data based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the Administrator), including profiling based on these provisions. The Administrator may no longer process these personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
6.5. Right to object to direct marketing - if personal data are processed for direct marketing purposes, the data subject has the right to object at any time to the processing of their personal data for such marketing, including profiling, to the extent that it is related to such direct marketing.
6.6. To exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending an appropriate message in writing or by email to the address indicated at the beginning of the privacy policy or by using the contact form available on the Online Store website.
### 7. COOKIES IN THE ONLINE STORE, OPERATIONAL DATA, AND ANALYTICS
7.1. Cookies are small text information in the form of text files sent by the server and stored on the side of the person visiting the Online Store website (e.g., on the hard drive of a computer, laptop, or on a smartphone's memory card - depending on the device used by the visitor). Detailed information about cookies and their history can be found, among others, here: http://en.wikipedia.org/wiki/HTTP_cookie.
7.2. The Administrator may process data contained in cookies during the use of the Online Store website by visitors for the following purposes:
- **Identifying Service Recipients as logged in to the Online Store and showing that they are logged in;**
- **Remembering Products added to the cart to place an Order;**
- **Remembering data from completed Order Forms, surveys, or login data to the Online Store;**
- **Adjusting the content of the Online Store website to the individual preferences of the Service Recipient (e.g., regarding colors, font size, page layout) and optimizing the use of the Online Store pages;**
- **Conducting anonymous statistics showing how the Online Store website is used;**
- **Remarketing, i.e., researching the characteristics of visitors' behavior to the Online Store by anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) to create their profile and deliver them ads tailored to their presumed interests, also when they visit other websites in the advertising network of Google Inc. and Facebook Ireland Ltd.**
7.3. By default, most web browsers available on the market accept saving cookies automatically. Everyone has the possibility to define the conditions for the use of cookies through the settings of their web browser. This means that you can, for example, partially limit (e.g., temporarily) or completely disable the possibility of saving cookies - in the latter case, however, this may affect some functionalities of the Online Store (for example, it may be impossible to go through the Order path via the Order Form due to not remembering Products in the cart in the following steps of placing the Order).
7.4. Web browser settings for cookies are important from the point of view of consent to the use of cookies by our Online Store - according to the regulations, such consent may also be expressed through web browser settings
. In the absence of such consent, you must appropriately change the settings of your web browser in terms of cookies.
7.5. Detailed information on changing the settings for cookies and their independent removal in the most popular web browsers is available in the help section of the web browser and on the following pages (just click on the given link):
- in the Chrome browser
- in the Firefox browser
- in the Internet Explorer browser
- in the Opera browser
- in the Safari browser
- in the Microsoft Edge browser
7.6. The Administrator may use the Google Analytics, Universal Analytics services provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) in the Online Store. These services help the Administrator analyze traffic in the Online Store. The collected data are processed within the above services in an anonymized manner (these are so-called operational data that prevent the identification of a person) to generate statistics helpful in administering the Online Store. These data are aggregate and anonymous, i.e., they do not contain identifying features (personal data) of visitors to the Online Store website. The Administrator using the above services in the Online Store collects such data as the sources and medium of acquiring visitors to the Online Store and how they behave on the Online Store website, information about devices and browsers from which they visit the site, IP and domain data, geographic data, and demographic data (age, gender) and interests.
7.7. It is possible to easily block the sharing of information about your activity on the Online Store website with Google Analytics - for this purpose, you can install the browser add-on provided by Google Inc. available here: https://tools.google.com/dlpage/gaoptout?hl=en.
7.8. The Administrator may use the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in the Online Store. This service helps the Administrator measure the effectiveness of advertisements and find out what actions visitors take on the Online Store website, as well as display tailored advertisements to those people. Detailed information on the operation of Facebook Pixel can be found at the following Internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
7.9. Managing the operation of Facebook Pixel is possible through the ad settings in your account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
### 8. FINAL PROVISIONS
8.1. The Online Store may contain links to other websites. The Administrator encourages you to read the privacy policy established there after switching to other websites. This privacy policy applies only to the Online Store of the Administrator.